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HTML WG last call comments to Authoring Tool Accessibility Guidelines 2.0

From: Steven Pemberton <steven.pemberton@cwi.nl>
Date: Wed, 26 Jan 2005 15:09:42 +0100
To: w3c-wai-au@w3.org
Message-ID: <opsk7qyg0esmjzpq@r600.lan>

Apologies for lateness.

- Section 1.2

Modify: Examples: timelines, waveforms, vector-based graphic editors, etc.
To include: objects which represent web implementations for graphical
widgets (menus, etc.).

Under indirect authoring functions include model-based authoring tools

- Guideline 1.1, 1.2

This section says conform to WCAG. For P1 this definition,
  includes the following in WCAG 1.0:

6.3 Ensure that pages are usable when scripts, applets, or other
programmatic objects are turned off or not supported. If this is not
possible, provide equivalent information on an alternative accessible page.
[Priority 1]

This is wrong and should be struck or should be written such that P1 can be
satisfied for WCAG 1.0 or WCAG 2.0 P1. Any reference to WCAG 1.0 should be
removed or modified. This WCAG 1.0 checkpoint is obsolete. I am concerned
that this impacts both JavaScript generated content as well as XForms
where, in fact, programmatic objects are bound to the data model and follow
an active MVC architecture. This would appear that a mode should be
available to turn active content off in the user agent and still work or
that someone would need to provide an alternative page equivalent for this
type of content although it is not how this would work in the case of forms
which are active.

- Guideline 1.3

The technique 1.3.1 for implementing this calls for respecting system font
and color information. How does this meet this checkpoint in and by itself?

- Guidline 1.4

This requires the author to perform structure-based edits. The document
structure being edited should be without error correction performed.
Assistive technology vendors often have to deal with bad content as the DOM
structure they are processing does not match that which is rendered. So, if
the authoring tool operates off of corrected content the results may not
meet the needs of the impaired user while being used by an assistive
technology. This should not be limited to only target device independence.

The second issue is that the author must be able to enumerate the available
actions which can be taken at a given object and selectively activate them.
For content which provides text equivalents for the corresponding action
such as the new access feature in XHTML 2.0 this information should be
provided to the author. An action may cause an action to occur which moves

- Guideline 1.5

In XHTML 2.0 we are introducing the role attribute and other important meta
data which is important for authoring tools. This includes search for text
equivalents for non-text objects. Does this include things like role meta
data which includes additional semantics vs. simply a text alternative?
This is not clear. It should be clarified either in the document or its

How do the navigation techniques here map to UAAG 1.0? Where is the
reference to UAAG 1.0?

- Guideline 2.1

This would indicate we (HTML working group) need to publish a WCAG 2.0
conformance techniques document for XHTML 2. This means any existing
content recommendation which does not have a WCAG conformance techniques
document does not comply with ATAG 2.0.

- Guideline 2.2

In this success criteria, I don't see why the ATAG group would allow the
author to be able to knowingly remove accessibility information (iii) and
still be compliant with this checkpoint

- Guideline 2.4
expand (e.g. to include objects which represent web implementations for
graphical widgets (menus, etc.).

- Guideline 3.5

This only addresses things like alternative text such that you could render
the alternative text alone and that would be adequate for the content user.
This guideline should be extended or a new guideline should be added to
include ANY accessibility related meta data. This will include Role meta
data in xhtml 2, XForms labels, XML event descriptions, upcoming state
attributes from the WAI PF working group. The role is not considered an
"alternative equivalent" as stated. Other information such as state data
are required for things like check boxes. This has a WCAG 1.0 flavor and
does not include new content being created which provides for improved

- Conformance section 2.1.2

Again, for WCAG compliance priority levels it should be either WCAG 2.0
priorities or WCAG 1.0 or WCAG 2.0 for a given priority level (not both).

The group is using ISO-TS-16071 to define the accessibility of the non-web
application . How does this map to 508? Are you introducing additional
requirements on companies. This may create a barrier to adoption in the
United States and other geos. Somebody from ATAG needs to provide a matrix
which describes the differences and equivalents for review and if adopted,
the matrix should be published.

Best wishes,

Steven Pemberton,
for the HTML WG
Received on Wednesday, 26 January 2005 14:09:45 GMT

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